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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND
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STATE OF ., ,
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COUNTY
PENNA.
FLORENCE j. PIERMATTEO
Plaintiff Ott'
MICHAEL P. PIERMATTEO
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Defendant
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DECREE h
DIVORCE
AND NOW, ............... .
decreed that ............. .FLORENCE T. PIERMATTEO
and ....................... MICHAEL, P.• PIERMATTEO• • • •
are divorced from the bonds of matrimony.
The court retains jurisdiction of the followir
been raised of record in this action for which a fi
been entered;
None
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...........................
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Attcet:
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it is ordered and
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3 claims which have
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Prothonotary
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FLORENCE T. PIERMATTEO,
Plaintiff
V.
MICHAEL P. PIERMATTEO,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-6506
CIVIL ACTION-LAW
DIVORCE
Transmit the record, together with the following information, to the Court for entry of
a divorce decree:
Ground for divorce: Irretrievable breakdown under Section 3301(d) of the
Divorce Code.
2. Date and manner of service of the Complaint: Service was accepted by the
Defendant on November 4, 1999, by certified, restricted, return-receipt, #Z015325718.
3. (a) Date of execution of the Plaintiffs Affidavit of Consent:
Defendant's Affidavit of Consent:
(b) (1) Date of execution of the affidavit required by Section 3301(d) of the
Divorce Code: January 12, 2000; (2) Date of filing and service of the plaintiffs affidavit upon
the respondent: Filed on January 12, 2000; served on Defendant on January 17, 2000.
4. Related claims pending: None.
5. (a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached: Served by depositing in the U.S. Mail, First
Class Postage on May 8, 2000.
Respectfully submitted.
?Y
Emily Long Hoffman, Esquire
Sup. Ct. ID k 66307
105 North Front Street
Harrisburg, PA 17108
(717)233-1112
Attorney for Plaintiff
Date: 6/20/00
...... ?.•riN .r .. ..... a ... _... _. -ti ?. ?.`+-?... .n. .? ?-?-- ?n4w..?.. ,..?W ..?Y
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below by depositing in the U.S. Mail, First Class Postage on this day:
Michael P. Pierrnatteo
639 South Main Street
Shrewsbury, PA 17361
Respectfully submitted,
By: `S=am dL?
Emily Long Hoffman, Esquire
Sup. Ct. ID N 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 6/20/00
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FLORENCE T. PIERMATTEO,
Plaintiff
V.
MICHAEL P. PIERMATTEO,
Defendant
TO: Michael P. Piermatteo
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-6506
CIVIL ACTION-LAW
DIVORCE
YOU have been sued in an action for divorce. You have failed to answer the
complaint or file a counter-affidavit to the 3301(d) affidavit. Therefore on or after May 2-0-,
2000, the Plaintiff can request the Court to enter a final Decree in Divorce.
If you do not file with the Prothonotary of the Court an answer with your signature
notarized or verified or a counter-affidavit by the above date, the Court can enter a final
Decree in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the
court is attached to this notice. Unless you have already filed with the Court a written claim
for economic relief, you must do so by the above date or the court may grant the divorce and
you will lose forever the right to ask for economic relief. The filing of the form counter-
affidavit alone does not protect your economic claims.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
r-?
I hereby certify that a true and correct copy of the attached document was served on the
person below by depositing in the U.S. Mail, First Class Postage on this day:
Mr. Michael P. Piermattco
Mann and Parker Lumber
335 N. Constitution Avenue
New Freedom, PA 17349
Res ctfully submitted,
By: 14-y'
Emily Long Hoffman, Esquire
Sup. Ct. ID N 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 5/8/00
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FLORENCE T. PIERMATTEO,
Plaintiff
V.
MICHAEL P. PIERMATTEO,
Defendant
IN TIIE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. q4• L s-UG Cu•LC Ti.-,
CIVIL ACTION-LAW
DIVORCE
You have been sued in Court. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail
to do so, the case may proceed without you and a Decree of Divorce or annulment may
be entered against you by the Court. A judgment may also be entered against you for
any other claim or relief requested in these papers by the Plaintiff. You may lose
money or property or other rights important to you.
When the ground for divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the office of the Prothonotary at the Cumberland County Courthouse,
Harrisburg, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM
ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
I Liberty Avenue
Carlisle, PA 17013
(717)249-3166
Le han dcmandado a usted en la torte. Si ustcd quicre defendersc de estas
demandas expuestas en las paginas siquicntes, usted tiene veintc (20) dias de plazo al
partir de lag fecha de la demanda y la notificacion. Usted dcbe presentar una
apariencia escrita o en persona o por abagado y archival en la torte en forma excrita
sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado
que si ustted no se defiende, la cone tomara medidas y puede entrar una orden contra
usted sin previo aviso o notificacion y por cualquier queja 0 alivio que cs pcdido en la
petition de demanda. Usted puede perdcr dinero o sus propiedades o otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABAGADO INMEDIATAMENTE. SI NO
TIENE ABAGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCURENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
1 Liberty Avenue
Carlisle, PA 17013
(717)249-3166
FLORENCE T. PIERMATfEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-6K0(r?tcG c-
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defcndant DIVORCE
DIVORCE COMPLAINT
I. Plaintiff is Florence T. Picrmatteo, who has resided at 1128 Fcmwood Avenue,
Camp Hill, Cumberland County, Pennsylvania 17011 for approximately two years.
2. Defendant is Michael P. Piermatteo, who has resided at 639 S. Main St.,
Shrewsbury, Pennsylvania, York County, Pennsylvania for approximately 1 month.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on December 23, 1994.
5. There have been no prior actions of divorce or annulment between the parties.
6. The parties arc not members of the Armed Forces.
7. The parties arc both citizens of the United States.
8. Plaintiff has been advised of tha availability of marriage counseling and that she
may have the right to request the Court to require the parties to participate in such counseling.
Being so advised, Plaintiff does not request that the Court require the parties to participate in
counseling prior to a divorce decree being handed down by the Court.
9. The Plaintiff avers that the marriage is irretrievably broken.
10. The Plaintiff avers as the grounds on which the action is based:
The marriage is irretrievably broken and the parties have been separated for two
years.
11. Paragraphs one through ten of Plaintiff's complaint are incorporated herein.
12. There is one child born of the marriage, Maddelaine A. Piermatteo born on
March 3, 1995.
13. Plaintiff desires primary physical custody of the minor child and is capable of
giving said child the necessary parental care and a proper and healthful environment.
14. The Plaintiff avers that she is a fit person to raise the minor child and that by
awarding her custody, the best interest and permanent welfare of the child will thereby be
promoted.
15. The parties' minor child has resided at 1128 Fernwood Avenue, Camp Hill,
Pennsylvania since June 1999.
16. Plaintiff has not participated in any other litigation concerning the custody
proceedings in a court of this or any other state, nor does she know of any person not a party
to these proceedings who has had physical custody of the child or claims to have custody or
visitation rights.
17. The Plaintiff requests that a reasonable visitation schedule be set up by the
Court regarding visitation of the parties' minor child by Defendant.
WHEREFORE, Plaintiff requests this Honorable Court:
(A) Enter a decree of divorce;
(B) Award primary physical custody of the child to the Plaintiff and establish a
reasonable visitation schedule for Defendant;
(C) Grant such further relief as the Court may deem equitable and just.
Respectfully submitted,
By: (/_
EMILY L NG HOFFMAN, ESQUIRE
Sup. Ct. I.D. # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108-1475
(717)233-1112
Date: IUAI- , k-i
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AFFIDAVIT
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Florence T. Piennatteo, being duly sworn according to law, deposes and says that the
facts contained in the foregoing Complaint in Divorce are true and correct to the best of the
below referenced party's knowledge, information and belie
A"
"-? Florence T. Pierrmnatteo
Date: jaizt. y `1
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FLORENCE 1'. PIERMATTEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-6506
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defendant DIVORCE
NOTICE TO THE. DEFENDANT
If you wish to deny any of the statements set forth in this Affidavit, you must file a
counter-affidavit within twenty (20) days after this Affidavit has been served on you, or the
statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER
SECTION 33010 OF THE DIVORCE COD F
1. The parties to this action separated on d 19_Zg and have
continued to live separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this Affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
FLORENCE T. PIERMATTEO
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FLORENCE T. PIERMATTEO,
Plaintiff
v
MICHAEL P. PIERMATTEO,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-6506
CIVIL ACTION-LAW
DIVORCE
1, Emily Long Hoffman, hereby certify that I served a true and correct copy of the
Divorce Complaint which was received by the Defendant on December 30, 1999, as set forth
below:
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Respectfully submitted,
Emily Long Hoffman
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
Attorney for Plaintiff
(717)233-1112
Date: 6120/00
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APR 2 6 2000 e
FLORENCE T. PIERMATTEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-6506
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defendant CUSTODY
AND NOW, this day of , 2000, it is hereby
ORDERED and DECREED that Defendant shall have custody of the minor child, Maddelaine
Piermatteo every other weekend from Friday at 5:00 p.m. until Sunday at 6:00 p.m. Defendant's
first weekend, for the purposes of determining which weekend is his, shall begin on Friday, April
29, 2000. Plaintiff shall have custody of the minor child at all other times. Defendant shall
provide all transportation for his custodial periods and shall provide a current address to Plaintiff.
This Order shall remain in effect until the Court is able to address this matter.
J.
APR 2 6 20000
FLORENCE T. PIERMATTEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99.6506
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defendant CUSTODY
AND NOW, this day of , 2000, it is hereby
ORDERED and DECREED that a hearing is scheduled for the day of
, 2000, at o'clock m. in Courtroom 4
at the Cumberland County Courthouse, Carlisle, Pennsylvania, to review Plaintiffs Petition for
Special Relief.
J.
APR 2 6 2000
FLORENCE T. PIERMATTEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-6506
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defendant CUSTODY
AND NOW, this day of , 2000, it is hereby
ORDERED and DECREED that Defendant shall have custody of the minor child, Maddelaine
Piermatteo every other weekend from Friday at 5:00 p.m. until Sunday at 6:00 p.m. Defendant's
first weekend, for the purposes of determining which weekend is his, shall begin on Friday, April
29, 2000. Plaintiff shall have custody of the minor child at all other times. Defendant shall
provide all transportation for his custodial periods and shall provide a current address to Plaintiff.
This Order shall remain in effect until the Cour, is able to address this matter.
J.
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APR 2 6 200011
FLORENCE T. PIERMATTEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-6506
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defendant CUSTODY
AND NOW, this day of , 2000, it is hereby
ORDERED and DECREED that a hearing is scheduled for the day of
. 2000, at o'clock _. m. in Courtroom #
at the Cumberland County Courthouse, Carlisle, Pennsylvania, to review Plaintiffs Petition for
Special Relief.
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Emily Long Hoffman
P.O. Box 11475
Harrisburg, PA 17108-1475
Mr. Michael P. Peirmatteo
Mann and Parker Lumber
335 N. Constitution Avenue
New Freedom, PA 17349
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EARLY LONG HOFFMAN
ATTORNEY AT LAW
PO BOX 11175
HARRISBURG, PA 17100
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EMR.Y LONG ROFFMAN
ATTORNEY AT LAw
PO BOX 11t; 5
HARRISBURC, PA I71CS
EMILY LONG HOFFMAN
ATTORNEY AT LAW
105 NORTH FRONT STREET
P. O. BOX 11,475
HARRISBURG, PA 17108.1475
255 MARKET STREET
MILLERSBURG, PA 17061
0171 602.4244
Curtis R. Long, Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
Re: Piermatteo v. Piermatteo
Dear Mr. Long:
f7171 233.1112
FAM7171 234•2234
a mail: haffmana0apia,nat
April 21, 2000
Enclosed please find our Petition for Special Relief to Maintain Status Quo in Custody
Matter and two copies thereof. We filed for a custody conciliation the other day and would like
to obtain a temporary order maintaining the status quo. I would appreciate if you would file this
with the proper office. I would also appreciate if you would time-stamp the copy and return it to
me in the enclosed envelope.
Thank you for your assistance.
Sy rely yours, fr?,V
Lon g if rm n
Enclosures
cc: Florence T. Piennaitco
. .
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
CIVIL ACTION LAW
+M?chGZ\ P, P1 cf'(y%C4 c7
Defendant CIVIL M9
CUSTODY VISITATION
ORDER OF COURT
And now, this i PO , upon consideration of the attached complaint, it is hereby directed
that the above parti s and their respective counse appear before
,
Esquire, the conciliator, at J tArcVTirm(S
Pennsylvania, on the day of , 2000, at t M P.M.,
for a Pre-hearing Custody Conference. At such conference, an effort will be made to resolve the
issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard
by the court, and to enter into a temporary order. All children age five or older may be present at
the conference. Failure to appear at the conference may provide grounds for the entry of a
temporary or permanent order.
FOR THE COURT:
By: 4 ? t Z&" t
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THE CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1-800.990-9108
FLORENCE T. PIERMATTEO, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
MICHAEL P. PIERMATTEO, .
Defendant : NO. 99-6506 CIVIL TERM
ORDER OF COURT
AND NOW, this (sjday of May, 2000, upon consideration of Plaintiffs Petition for
Special Relief To Maintain Status Quo in Custody Matter, this matter is referred to the
custody conciliation process, and the Court Administrator is requested to facilitate this
referral.
BY THE COURT,
Emily Long Hoffman, Esq.
105 North Front Street
Harrisburg, PA 17108
Attorney for Plaintiff
Michael P. Piermatteo
Mann and Parker Lumber
335 N. Constitution Avenue
New Freedom, PA 17349
Defendant, Pro Se
Court Administrator
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FLORENCE T. PIERMATTEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. No. 99-6506
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defendant CUSTODY
AND NOW, this day of , 2000, it is hereby
ORDERED and DECREED that Defendant shall have custody of the minor child, Maddelaine
Piermattco every other weekend from Friday at 5:00 p.m. until Sunday at 6:00 p.m. Defendant's
first weekend, for the purposes of determining which weekend is his, shall begin on Friday, April
29, 2000. Plaintiff shall have custody of the minor child at all other times. Defendant shall
provide all transportation for his custodial periods and shall provide a current address to Plaintiff.
This Order shall remain in effect until the Court is able to address this matter.
J.
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FLORENCE T. PIERMATTEO, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
i
V. No. 99-6506
MICHAEL P. PIERMATTEO, CIVIL ACTION-LAW
Defendant CUSTODY
ORDER
AND NOW, this day of , 2000, it is hereby
ORDERED and DECREED that a hearing is scheduled for the day of
, 2000, at o'clock m. in Courtroom #
at the Cumberland County Courthouse, Carlisle, Pennsylvania, to review Plaintiffs Petition for
Special Relief.
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FLORENCE T. PIERMATTEO,
Plaintiff
V.
MICHAEL P. PIERMATTEO,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-6506
CIVIL ACTION-LAW
CUSTODY
AND NOW, comes Florence T. Piennatteo, Plaintiff, by and through her attorney, Emily
Long Hoffman, and in support of her Petition for Special Relief avers as follows:
1. Florence T. Peirmatteo, Plaintiff (hereinafter referred to as "Mother'), recently filed a
complaint requesting a custody conciliation conference which has not yet been scheduled to
maintain the status quo with regard to custody of her minor child, Maddelaine A. Peermatteo,
born March 3, 1995.
2. Michael P. Peirmatteo, Defendant (hereinafter referred to as "Father'), is the Father of
the minor child, Maddelaine.
3. Mother desires that an interim order be entered which maintains the status quo
schedule which schedule has been in effect since June 15, 1999.
4. The status quo schedule has been that Father has custody of Maddelaine every other
weekend which weekend begins on Friday at approximately 5:00 p.m. and ends on Sunday at
approximately 6:00 p.m.
5. Father provides all transportation relative to his custodial periods.
6. Mother desires an interim order because Father has gradually been returning the minor
child later and later each Sunday night.
7. During Father's latest custodial period, Father returned the child at approximately 9:45
on Sunday evening which Mother believes is too late for a four-year old child as the child must
be up at 7:00 a.m. the next morning for prc-school.
8. Mother asked Father to please return the child by 6:00 p.m. to which Father replied,
"What are you going to do about it if I don't".
9. Father will not tell Mother the address of his current residence.
10. Mother is deeply concerned that Father will disregard the current schedule which will
be harmful to the minor child.
11. Mother desires that the current schedule be adhered to until the court may address
this matter.
12. Pa.R.C.P. 1915.13 gives this Court the authority to enter an Order for Special Relief.
WHEREFORE, Mother respectfully requests that this Honorable Court maintain the
current schedule of Father having custody of the minor child every other weekend from Friday at
5:00 p.m. until Sunday at 6:00 p.m. with Father to provide all transportation and a current
address to Mother. Mother shall have custody of the minor child at all other times until the Court
is able to address this matter.
Respectfully submitted,
' ON,
Emily Lon Hoffman, Esquire
Sup. Ct. ID # 66307
105 North Front Street
Harrisburg, PA 17108
(717)233-1112
Date: 411-i I,
04/20,00 18:23 FAI 717 697 6897 CO..'MNEATAL ®08
Apr-20-00 12:31P CMILY LONG HOFFMAN• 717 234 2234 P.02
Upon my powmal knowledge. info mstion, and belief, I, Morcow T. Piermatteo, verify
that the ikets avem¢d and statements made in the foregoing document are true and emroct to the
best of my knowledge.
I understand that false sutemema or Averments therein mado will subject me to the
criminal penalties of 18 Pa.C.S. Section 4904 relating to unswom Wall ou to authorities.
DATE: B lwafte-e Florence T. Piamattoo
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below by depositing in the U.S. Mail, First Class Postage on this day:
Mr. Michael P. Peirmatteo
Mann and Parker Lumber
335 N. Constitution Avenue
New Freedom, PA 17349
Respectfully submitted,
By:
Emily Long Hoffman, Esquire
Sup. Ct. 1D // 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
Date: 4/21/00
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FLORENCE T. PIERMATTEO,
Plaintiff
V.
MICHAEL P. PIERMATTEO,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-6506
CIVIL ACTION-LAW
CUSTODY
You, Michael Piermatteo and Florence Piermatteo, are ORDERED to appear in person before
?1 C 5-1 `C?4` Custody Conciliator, at -, j9 \,j . ?Aa IS ? t
?1t-Chflf?\C 1 i- - on (ltt -i.1_- a1`?v -?oc( atILP
_ o'clock A-, m. for a Custody Conciliation Conference. At such Conference, an effort will be made to
resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the
Court, and to enter into a Temporary Order. All children age five or older may, at the request of either attorney or
party, be present at the Conference. Failure to appear at the Conference may provide grounds for the entry or a
temporary or permanent Order.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717)249.3166
1-800-990.9108
FOR THE COURT:
Date: cr, C I 1. .
Custody Conciliator I,
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9. The Plaintiff nvcrs that the marriage is irretrievably broken.
10. The Plaintiff avers as the grounds on which the action is based:
The marriage is irretrievably broken and the pnrtics have been separated for two
years.
If. Paragraphs one lhnmgh tco of Plaintiff's complaint arc incorporated herein.
12. There is one child horn of Ilse marriage, Maddelainc A. Picrmalteo born un
March 3, 1995.
13. Plaintiff desires primary physical custody of the minor child and is capable of
giving said child the necessary parental care and a proper and healthful environment.
14. The Plaintiff avers that she is a fit person to raise the minor child and that by
awarding her custody, the best interest and permanent welfare of the child will thereby be
promoted.
15. The parties' minor child has resided at 1128 I'crnwoud Avenue, Camp 11111,
Pennsylvania since June 1999.
16. Plaintiff has not participated in any other litigation concerning the custody
proceedings in a court of this or any other state, nor does she know of any person not a party
to these proceedings who has had physical custody of the child or claims to have custody or
visitation rights.
17. 'fhc Plaintiff requests ow a reasonable viehalion schedule be set up by the
court regarding visitation of the parties' minor child by Ucfcndant.
N111'sRhl'OI(1:, Plaintiff requests this lionurable Cowl:
(A) 1?1tcr a decree of divorce;
(11) Award primary physical custody of the child to the I'Iainliff and esloidish a
reasonable visilation scitcduic fur Defendant;
((') (leant such further relief ne the Court may deem cquilahle and just.
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Itcsspcoff`fu'lly submitted,
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I ,-,,.Y L NU IIUPITIAN, ESQUIRE
Sup. Ct. 1.1). M 66307
105 North Front Street
1`.U.Ilnx IIA75
Iiarrishurg, PA 17108-ld75
(717)233.1112
AFFIDAVIT
I'lorence'i'. Picnmattco. being duly sworn according to Inw, deposes and says that the
facts contained in the foregoing Complaint in Divorce are true and correct to the best of the
below referenced party's knowledge. information and belie
Florence T. Piennntleo'
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the attached document was served on the
person below by depositing in the U.S. Mail, First Class Postage on this day:
Mr. Michael P. Peirmatteo
Mann and Parker Lumber
335 N. Constitution Avenue
New Freedom, PA 17349
Respectfully submitted,
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Emily Lon H fman, Esquire
Sup. Ct. ID # 66307
105 North Front Street
P.O. Box 11475
Harrisburg, PA 17108
(717)233-1112
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FLORENCE T. PIERMAITEO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 99-6506 CIVIL TERM
MICHAEL P. PIERMATTEO, : CIVIL ACTICN - LAW
Defendant IN CUSTODY
ORDER OF COURT
AND NOW, this Z r2 A day of Jo n , , 20001 upon
consideration of the attar Custody Conc at on Report, t is ordered
and directed as follows:
1. The parties shall submit themselves, their minor Child, and any
additional persons deemed necessary by the evaluator to a custody
evaluation to be performed by a professional selected by agreement of the
parties. The purpose of the evaluation shall be to obtain independent
professional recommendations concerning ongoing primary and partial
physical custody arrangements which will best serve the interests of the
Child. The parties shall share all costs of the evaluation equally.
2. Pending completion of the evaluation and order of Court or
agreement of the parties, the Child shall continue to reside with the
Mother subject to the following periods of partial custody for the Father:
The Father shall have custody of the Child on alternating
weekends from Friday through Sunday through July 16, 2000
and also subsequent to August 12, 2000. In addition, the
Father shall have custody of the Child from Sunday, July
16, 2000 at 6:00 p.m. through Saturday, August 12, 2000
at 6:00 p.m. with the exception of the period from July
28, 2000 at a time to be arranged by agreement of the
parties through July 30, 2000 at 6:00 p.m. during which
period the mother shall have custody of the Child.
3. Upon completion of the custody evaluation and in the event the
parties are not able at that time to reach an agreement as to ongoing
custody arrangements, counsel for either party or a party Pro Se, may
contact the Conciliator within 60 days of the evaluation report to schedule
an additional Custody Conciliation Conference.
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4. This order is entered pursuant to an agreement of the parties at a
Custody Conciliation Conference. The parties may modify the provisions of
this order by mutual consent. In the absence of mutual consent, the terms
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of this Order shall control.
cc: Emily Long Hoffman, Esquire - Counsel for Mother
Michael P. Piermatteo, Father
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BY THE COURT,
FLORENCE T. PIERMATTEO,
Plaintiff
VS.
MICHAEL P. PIERMATTEO,
Defendant
PRIOR JUDGE: J. Wesley Oler, Jr.
IN THE COURT OF CCMMCN PLEAS OF
CUMBERLAND OOUNTY, PENNSYLVANIA
NO. 99-6506 CIVIL TERM
CIVIL ACTION - LAW
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN AOOORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-B, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME DATE OF BIM CURRENTLY IN CUSTODY OF
Maddelaine (or Madeline)
A. Piermatteo May 3, 1995 Mother
2. A Conciliation Conference was held on June 21, 2000, with the
following individuals in attendance: The Mother, Florence T. Piermatteo,
with her counsel, Emily Long Hoffman, Esquire, and the Father, Michael P.
Piermatteo, who is not represented by counsel in this matter.
3. The parties agreed to entry of an order in the form as attached.
Date a ,? Jo a Dawn S. Sunday, Esqu re
Custody Conciliator
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